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August 26, 1992 Ms Nancy K. Lancaster Compliance Unit, Surveillance Dept. of Toxic Substances Control Page 2. Periodically, water accumulates beneath the Christy Box.' When the wells are inspected during sampling events, any ponded water is manually and fully purged prior to opening the well. oThe inspector stated that there was not a lock on MW -5B. To the best of our knowledge, the steel vault protecting the wells are kept locked at all times, except when water level measurements are obtained and while ground water is pumped from the wells. The lock for well MW -5B may have been misplaced during a previous sampling event. The lock for well MW -5B has been replaced. Items 3 - 7 of the alleged Schedule of Violations are all inter -related, and are specifically addressed below. However, to put our responses in context, it is important to note certain pertinent background information. As previously discussed with Nancy Lancaster and Debbie McDowell, we are still in the process of obtaining final post closure cost estimates. We are currently and have been working with the Facility Permitting Unit on a determination of final. post closure cost estimates. EBA Wastechnologies prepared the Post Closure Plan for WMU-A in April, 1989, which contained the initial post closure cost estimate. Forward's financial assurance activities to date, as you have documented in your files, are based on that cost estimate. Subsequently, Ms. Pamela A. Johnson of the DTSC informed us in a letter dated April 1990 that our monitoring requirements had been changed due to Federal Regulations. Kleinfelder performed the 1990 post closure monitoring in accordance with Ms. Johnson's letter. It quickly became apparent that a great deal of the newly required monitoring activity and data analysis provided little useful information and even obscured the analysis of significant data. Kleinfelder noted in the 1990 Annual Report for the Forward Landfill t ' hat a Rescoping Proposal was necessary and would be sent to the DTSC in early 1991 for approval. This Rescoping Proposal was submitted to the DTSC on April 12, 1991. The goal of the proposal was to 1) decrease the number of constituents to be monitored, 2) unify and reconcile the RWQCB, DTSC, and EPA monitoring requirements, and 3) institute a monitoring program that can better generate significant data for statistical analysis and also serve as a reliable check on ground water quality.